IR 05000293/2006009
| ML062560357 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/13/2006 |
| From: | Rogge J Engineering Region 1 Branch 3 |
| To: | Balduzzi M Entergy Nuclear Operations |
| References | |
| IR-06-009 | |
| Download: ML062560357 (23) | |
Text
ber 13, 2006
SUBJECT:
PILGRIM NUCLEAR POWER STATION - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000293/2006009
Dear Mr. Balduzzi:
On August 11, 2006, the NRC completed a triennial fire protection team inspection at the Pilgrim Nuclear Power Station. The enclosed report documents the inspection findings which were discussed at an exit meeting on August 11, 2006, with Mr. K. Bronson and other members of your staff.
This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, no findings of significance were identified. However, a licensee identified violation which was determined to be of very low safety significance is listed in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section VI.A of the NRC Enforcement Policy because of the very low safety significance of the violation and because it is entered into your corrective action program. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspectors at the Pilgrim Nuclear Power Station.
M In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/ADAMS.html (the Public Electronic Reading Room).
Sincerely,
/RA/
John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-293 License No. DPR-35 Enclosure: Inspection Report No. 05000293/2006009 cc w/encl:
G. J. Taylor, Chief Executive Officer, Entergy Operations M. Kansler, President, Entergy Nuclear Operations, Inc.
J. T. Herron, Senior Vice President and Chief Operating Officer C. Schwarz, Vice-President, Operations Support S. J. Bethay, Director, Nuclear Safety Assurance O. Limpias, Vice President, Engineering J. F. McCann, Director, Licensing C. D. Faison, Manager, Licensing M. J. Colomb, Director of Oversight, Entergy Nuclear Operations, Inc.
B. S. Ford, Manager, Licensing, Entergy Nuclear Operations, Inc.
T. C. McCullough, Assistant General Counsel S. Lousteau, Treasury Department, Entergy Services, Inc.
R. Walker, Radiation Control Program, Dept. of Public Health, Commonwealth of Massachusetts The Honorable Therese Murray The Honorable Vincent deMacedo Chairman, Plymouth Board of Selectmen Chairman, Duxbury Board of Selectmen Chairman, Nuclear Matters Committee Plymouth Civil Defense Director D. OConnor, Massachusetts Secretary of Energy Resources J. Miller, Senior Issues Manager Office of the Commissioner, Massachusetts Department of Environmental Protection Office of the Attorney General, Commonwealth of Massachusetts Electric Power Division, Commonwealth of Massachusetts R. Shadis, New England Coalition Staff D. Katz, Citizens Awareness Network
M
SUMMARY OF FINDINGS
IR 05000293/2006009; 07/24/2006 - 08/11/2006, Entergy Nuclear Operations, Inc., Pilgrim
Nuclear Power Station; Triennial Fire Protection Team Inspection.
This report covered a two-week triennial fire protection team inspection by three Region I inspectors. One Green finding was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649,
Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
No findings of significance were identified.
Licensee-Identified Violations
A violation of very low safety significance, which was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective actions are listed in Section 4OA7 of this report.
ii
REPORT DETAILS
Background This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 71111.05T, Fire Protection. The objective of the inspection was to assess whether Entergy has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Pilgrim Nuclear Power Station. The following fire areas (FAs) and fire zones (FZs) were selected for detailed review based on risk insights from the Individual Plant Examination (IPE)/Individual Plant Examination of External Events (IPEEE):
C Fire Area 1.9 (Zone 2.2)
C Fire Area 1.10 (Zones 2.4, 2.9, 2.10)
C Fire Area 3.2 C Fire Area 4.3 The inspection team evaluated the licensees fire protection program (FPP) against applicable requirements which include plant Technical Specifications, Operating License Condition 3.F, NRC Safety Evaluations, 10 CFR 50.48 and 10 CFR 50 Appendix R. The team also reviewed related documents that include the Updated Final Safety Analysis Report Section 10.8, the Fire Hazards Analysis and the Post-Fire Safe Shutdown Analysis Report.
Specific documents reviewed by the team are listed in the attachment.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems
1R05 Fire Protection
.01 Post-Fire Safe Shutdown From Outside Main Control Room (Alternative Shutdown) and
Normal Shutdown
a. Inspection Scope
Methodology The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation drawings (P&IDs), electrical drawings, the UFSAR and other supporting documents to verify that hot and cold shutdown could be achieved and maintained from outside the control room for fires that rely on shutdown from outside the control room.
This review included verification that shutdown from outside the control room could be performed both with and without the availability of offsite power. Plant walkdowns were also performed to verify that the plant configuration was consistent with that described in the safe shutdown and fire hazards analyses. These inspection activities focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor decay heat removal, process monitoring instrumentation and support systems functions. The team verified that the systems and components credited for use during this shutdown method would remain free from fire damage. The team verified that the transfer of control from the control room to the alternative shutdown locations would not be affected by fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for alternative shutdown control circuits).
Similarly, for fire areas that utilize shutdown from the control room, the team also verified that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe shutdown conditions.
Operational Implementation The team verified that the training program for licensed and non-licensed operators included alternative shutdown capability. The team also verified that personnel required for safe shutdown using the normal or alternative shutdown systems and procedures are trained and available onsite at all times, exclusive of those assigned as fire brigade members.
The team reviewed the adequacy of procedures utilized for post-fire shutdown and performed an independent walk through of procedure steps to ensure the implementation and human factors adequacy of the procedures. The team also verified that the operators could be reasonably expected to perform specific actions within the time required to maintain plant parameters within specified limits. Time critical actions which were verified included restoration of AC electrical power, establishing control at the remote shutdown and local shutdown panels to provide reactor coolant makeup and decay heat removal.
Specific procedures reviewed for alternative shutdown, including shutdown from outside the control room included the following:
C 2.4.143, Shutdown From Outside Control Room, Rev. 35 C 2.4.143.1, Shutdown With a Fire in Reactor Building East (Fire Area 1.9), Rev. 13 C 2.4.143.2, Shutdown With a Fire in Reactor Building West (Fire Area 1.10), Rev. 14 The team reviewed manual actions to ensure that they had been properly reviewed and approved and that the actions could be implemented in accordance with plant procedures in the time necessary to support the safe shutdown method for each fire area. The team also reviewed the periodic testing of the alternative shutdown transfer capability and instrumentation and control functions to ensure the tests are adequate to ensure the functionality of the alternative shutdown capability.
b. Findings
No findings of significance were identified.
.02 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The team reviewed the fire hazards analysis, safe shutdown analyses and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The team ensured that separation requirements of Section III.G of 10 CFR 50 Appendix R were maintained for the credited safe shutdown equipment and their supporting power, control and instrumentation cables. This review included an assessment of the adequacy of the selected systems for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and associated support system functions.
The team reviewed the licensee procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the FHA. A sample of hot work and transient combustible control permits were also reviewed. The team performed plant walkdowns to verify that protective features were being properly maintained and administrative controls were being implemented.
The team also reviewed the licensees design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the fire protection program and/or post-fire safe shutdown analysis and procedures.
b. Findings
No findings of significance were identified.
.03 Passive Fire Protection
a. Inspection Scope
The team walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including walls, fire doors and fire dampers), and electrical raceway fire barriers to ensure they were appropriate for the fire hazards in the area.
The team reviewed installation/repair and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design. The team also reviewed similar records for fire protection wraps to ensure the material was of an appropriate fire rating and that the installation met the engineering design.
b. Findings
No findings of significance were identified.
.04 Active Fire Protection
b. Inspection Scope
The team reviewed the design, maintenance, testing and operation of the fire detection and suppression systems in the selected plant fire areas. This included verification that the manual and automatic detection and suppression systems were installed, tested and maintained in accordance with the NFPA code of record and that they would control and/or extinguish fires associated with the hazards in the selected areas. A review of the design capability of suppression agent delivery systems were verified to meet the code requirements for the fire hazards involved. The team also performed a walkdown of accessible portions of the detection and suppressions systems in the selected areas as well as a walkdown of major system support equipment in other areas (e.g. fire protection pumps, Halon and/or CO2 storage tanks and supply system) to assess the material condition of the systems and components.
The team reviewed electric and diesel fire pump flow and pressure tests to ensure that the pumps were meeting their design requirements. The team also reviewed the fire main loop flow tests to ensure that the flow distribution circuits were able to meet the design requirements.
The team also assessed the fire brigade capabilities by reviewing training, qualification and drill critique records. The team also reviewed pre-fire plans and smoke removal plans for the selected fire areas to determine if appropriate information was provided to fire brigade members and plant operators to identify safe shutdown equipment and instrumentation, and to facilitate suppression of a fire that could impact post-fire safe shutdown. In addition, the team inspected the fire brigades protective ensembles, self-contained breathing apparatus (SCBA), and various fire brigade equipment (including smoke removal equipment) to determine operational readiness for fire fighting.
b. Findings
A licensee identified violation of the fire detection and suppression requirements of 10 CFR 50 Appendix R is discussed in section 4OA7 of this report.
.05 Protection From Damage From Fire Suppression Activities
a. Inspection Scope
The team performed document reviews and plant walkdowns to verify that redundant trains of systems required for hot shutdown are not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified that:
1. A fire in one of the selected fire areas would not directly, through production of smoke, heat or hot gases, cause activation of suppression systems that could potentially damage all redundant trains; 2. A fire in one of the selected fire areas (or the inadvertent actuation or rupture of a fire suppression system) would not directly cause damage to all redundant trains (e.g. sprinkler caused flooding of other than the locally affected train).
3. Adequate drainage is provided in areas protected by water suppression systems.
b. Findings
No findings of significance were identified.
.06 Normal and Alternative Shutdown Capability
a. Inspection Scope
Alternative shutdown capability for the areas selected for inspection utilizes shutdown from outside the control room and is discussed in section 1R05.01 of this report.
.07 Circuit Analyses
a. Inspection Scope
The inspectors verified that the licensee performed a post-fire safe shutdown analysis for the selected fire areas and that the analysis appropriately identified the structures, systems and components important to achieving and maintaining safe shutdown.
Additionally, the team verified that the licensees analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts, shorts to ground or other failures were identified, evaluated and dispositioned to ensure spurious actuations would not prevent safe shutdown.
The team reviewed and considered fire and cable attributes, potential undesirable consequences and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, multiple spurious actuations, actuations resulting in flow diversion or loss of coolant events.
The team also reviewed cable raceway drawings for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the cable routing matrices.
Cable failure modes were reviewed for the following components:
C MO1001-47, RHR Shutdown Cooling Valve C MO1001-50, RHR Shutdown Cooling Valve C 152-509, EDG A Output Circuit Breaker C 152-504, Bus A5" Supply Circuit Breaker (from startup transformer)
C 203-3C, Automatic Blowdown Valve The team reviewed circuit breaker coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted due to a lack of coordination. The team confirmed that coordination studies had addressed multiple faults due to fire. Additionally, the team reviewed a sample of circuit breaker maintenance and records to verify that circuit breakers for components required for post-fire safe shutdown were properly maintained in accordance with procedural requirements.
b. Findings
No findings of significance were identified.
.08 Communications
a. Inspection Scope
The team reviewed safe shutdown procedures, the safe shutdown analysis and associated documents to verify an adequate method of communications would be available to plant operators following a fire. During this review the team considered the effects of ambient noise levels, clarity of reception, reliability and coverage patterns.
The team also inspected the designated emergency storage lockers to verify the availability of portable radios for the fire brigade and for plant operators. The inspectors also verified that communications equipment such as repeaters, transmitters, etc. would not be affected by a fire.
b. Findings
No findings of significance were identified.
.09 Emergency Lighting
a. Inspection Scope
The team observed the placement and coverage area of eight-hour emergency lights throughout the selected fire areas to evaluate their adequacy for illuminating access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post-fire safe shutdown. The team also verified that the battery power supplies were rated for at least an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> capacity. Preventive maintenance procedures, the vendor manual, completed surveillance tests and battery replacement practices were also reviewed to verify that the emergency lighting was being maintained in a manner that would ensure reliable operation.
b. Findings
No findings of significance were identified.
.10 Cold Shutdown Repairs
a. Inspection Scope
The team verified that the licensee had dedicated repair procedures, equipment, and materials to accomplish repairs of components required for cold shutdown which might be damaged by the fire to ensure cold shutdown could be achieved within the time frames specified in their design and licensing bases. The inspectors verified that the repair equipment, components, tools and materials (e.g. pre-cut cables with prepared attachment lugs) were available and accessible on site.
b. Findings
No findings of significance were identified.
.11 Compensatory Measures
a. Inspection Scope
The team verified that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g. detection and suppression systems and equipment, passive fire barriers, or pumps, valves or electrical devices providing safe shutdown functions or capabilities). The team also verified that the short term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that the licensee was effective in returning the equipment to service in a reasonable period of time.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
.01 Corrective Actions for Fire Protection Deficiencies
a. Inspection Scope
The team verified that the licensee was identifying fire protection and post-fire safe shutdown issues an appropriate threshold and entering them into the corrective action program. The team also reviewed a sample of selected issues to verify that the licensee had taken or planned appropriate corrective actions.
b. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The team presented their preliminary inspection results to Mr. K. Bronson and other members of the site staff at an exit meeting on August 11, 2006. No proprietary information was included in this inspection report.
4AO7 Licensee-Identified Violations The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV.
Cornerstone: Mitigating Systems
Section III.G.3 of 10 CFR 50, Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979, requires, in part, that a fixed fire detection and suppression system be installed in areas under consideration for alternative post-fire safe shutdown capability. Contrary to this requirement, selected fire zones within fire areas 1.9 and 1.10 did not have either fixed detection (zones 2.9 and 2.10) or fixed suppression (zone 2.2), nor were these zones included in exemption requests associated with this requirement. This issue was determined to be more than minor because it affected the configuration control attribute of the mitigating system cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events. The inspectors determined the finding was of very low safety significance (Green) because the licensees safe shutdown analysis identified potential fire damage to equipment in the areas and appropriate plant procedures were in place to operate affected systems required for post-fire safe shutdown. Also, the absence of detection or suppression in the affected zones would not result in a control room evacuation and thus would not require the use of the more difficult alternative procedure for shutdown from outside the control room. This issue has been entered in the licensees corrective program (CR PNP-2006-00440).
A- 2 ATTACHMENT
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- R. Blagbrough, Engineering
- S. Burke, Fire Protection
- R. Daverio, Engineering
- S. Das, Engineering
- F. McGinnis, Licensing
- C. McMorrow, Fire Brigade Training
- L. Simmons, System Engineer
NRC
- J. Rogge, Chief, Engineering Branch 3, Division of Reactor Safety
- W. Raymond, Senior Resident Inspector, Pilgrim Nuclear Power Station
- C. Welch, Resident Inspector, Pilgrim Nuclear Power Station
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
NONE Open and
Closed
NONE
Closed
NONE
Discussed
NONE